Privacy Policy

June 25, 2024
The NT entity (see Legal Entity for details, hereinafter collectively referred to as "NT" or "we") provides this Privacy Policy to describe how we collect, use, and share information. In accordance with European data protection laws, NT is the data controller of your personal information. This Privacy Policy (hereinafter referred to as the "Policy") will describe NT's processing of the following two types of information:
(1) Personal information we process in the course of providing the NT platform, software, technology, tools, or any services offered by NT (the "NT Services" or "Services");
(2) Information we obtain from website visitors through our website http://wenyu.netshorttv.com/ or other websites containing this Policy, as well as login portals and other services we provide for our clients or business partners (the "NT Websites," "Sites," or "Website").

This Privacy Policy is subject to the Service Agreement between NT and you. Please read this Privacy Policy before using the NT Services or NT Websites. By using the NT Services or NT Websites, you acknowledge that you have read, understood, and agreed to this Privacy Policy.

To further improve our privacy policy and services, we will amend this Privacy Policy from time to time. If this Privacy Policy undergoes material changes, we will post a notice on the NT Website before the new privacy policy becomes effective.

Data protection and ensuring the trust of our business partners and you are at the core of NT's business principles. Therefore, compliance with applicable data protection regulations is our primary mission. This Policy has been updated to comply with the requirements of applicable data protection laws, including the EU General Data Protection Regulation ("GDPR"), the U.S. Children's Online Privacy Protection Act ("COPPA"), the California Consumer Privacy Act ("CCPA"), and the Brazilian General Data Protection Law ("LGPD").

For the purposes of this Privacy Policy, an "entrusted processor" refers to an entrusted processor under the Personal Information Protection Law of the People's Republic of China, a "processor" under the GDPR and VCDPA, and a "service provider" under the CCPA. A "personal information processor" refers to a personal information processor under the Personal Information Protection Law of the People's Republic of China, a "controller" under the GDPR and VCDPA, and a "business" under the CCPA.

NT Services Privacy Policy

1. Introduction

This Privacy Policy applies to NT's personal information processing activities in the following situations: (i) NT's business partners use or interact with the NT Services; or (ii) end-users ("Users") use the platforms, applications, websites, or other services provided by NT's business partners.
NT provides one-stop, cross-channel intelligent advertising services to its business partners. For the purposes of these services, business partners will entrust us to collect and use personal information related to Users. In the course of business communications with our business partners, NT will also process the personal information of our business partners' contacts.
Unless otherwise explicitly stated in this Privacy Policy, in the course of providing the Services, NT acts as a delegated processor, strictly processing your personal information in accordance with the purposes and methods of processing entrusted to us by our business partners. Our business partners, as personal information controllers, independently determine the purposes and methods of such personal information processing activities.
The NT Services may link to third-party websites, applications, or other third-party content. Please be aware that we cannot control how third parties process user information, and third parties may have privacy practices that differ from those described in this Privacy Policy.

2. How We Collect User Information

We collect information through our business partners: (1) Our business partners may transmit user information to us; (2) When we access third-party platforms (e.g., advertising platforms, aggregation platforms, monetization platforms, attribution platforms) with the authorization and/or entrustment of our business partners, these third-party platforms may transmit user information to us.
To provide NT Services to our business partners, we collect information from their contacts. We contractually require our business partners to obtain valid consent on our behalf from their contacts for our collection and use of their personal information as a data controller.
Regarding the collection of the aforementioned personal information and the acquisition of valid consent, we have required in our cooperation agreements with our business partners that they promise and guarantee the legality of the source of the personal information. They must also inform individuals of the specific details of our processing of their personal information in accordance with applicable laws and obtain their valid consent (and separate consent where required by applicable law), ensuring that individuals can withdraw such consent at any time.

3. Information We May Collect from Users

(1) When we provide NT services to our business partners, we may collect the following information from Users: a. Information transmitted to us by our business partners: International Mobile Equipment Identity (IMEI), Apple IDFA, IDFV, Android ID, GAID, OAID, MAC address; IP address; advertising behavioral data, such as cost, impressions, clicks, conversions, revenue, retention, etc. b. Information transmitted to us by third-party platforms accessed with the authorization and/or entrustment of our business partners: International Mobile Equipment Identity (IMEI), Apple IDFA, IDFV, Android ID, GAID, OAID, MAC address; IP address; advertising behavioral data, such as cost, impressions, clicks, conversions, revenue, retention, etc.
(2) We may also collect the names, job titles, email addresses, account names and passwords, IP addresses, and contact addresses of our business partners' contacts.

4. Regarding Sensitive Personal Information

Sensitive Personal Information generally refers to personal information that, if leaked or used illegally, could easily lead to the infringement of a natural person's dignity or harm to their personal or property safety. The scope of such information may vary according to different applicable laws.
We will not collect your Sensitive Personal Information without your valid consent. Our business partners will only transmit or authorize us to process your Sensitive Personal Information after fully informing you of the necessity of such processing and its impact on your personal rights and interests and obtaining your consent in accordance with the law.

5. How We Use Your Personal Information

We use your personal information in the following ways:

6. Legal Basis for Processing Personal Information

Consent. As required by applicable law, we contractually require our business partners to obtain consent on our behalf from users or their employees for the processing activities described in this Privacy Policy. Users or their employees may withdraw their consent at any time.

7. Sharing, Commissioned Processing, Transfer, Public Disclosure, and International Transfer of Your Personal Information

(1) Sharing
We will not share user personal information with other third parties without the user's authorized consent.
(2) Commissioned Processing

8. Your Data Rights

You have the right to access, modify, amend, or delete the personal information we may have collected about you. To exercise these rights, please contact privacy@netshorttv.com.
If you are located in the European Economic Area, you have the following rights (subject to limited exceptions): (i) to request access to, modification of, or deletion of your personal information; (ii) to restrict or object to the processing of your personal information; and (iii) to request an electronic copy of your personal information for transmission to another party or third party. You also have the right to lodge a complaint with your local data protection authority in the EEA regarding the processing of your personal information.

If you are a resident of California, USA, you may inquire about our collection and use of your personal information over the past 12 months, including:

• The categories of personal information we have collected.
• The categories of sources from which we collect personal information.
• The business or commercial purpose for collecting, selling, and/or sharing personal information.
• The categories of third parties with whom we disclose personal information.
• The categories of personal information we sold, shared, or disclosed for a business purpose.
• The third parties to whom we sold, shared, or disclosed personal information for a business purpose.
• Your Rights. You may request a copy of the personal information we have collected about you in the past 12 months.
• You may request that we delete the personal information we have collected from you.
• You may request that we correct your personal information.

As provided by the CCPA, you have the right to not be discriminated against for exercising the above rights.
You may exercise your California privacy rights by (i) sending a written request to privacy@netshorttv.com or by mail to: Legal Department, Room 3-2-25, Building 3, Science and Technology Park, No. 37 Daoyi South Street, Shenbei New District, Shenyang, Liaoning, China; (ii) sending a written request to privacy@netshorttv.com to limit the use of your sensitive personal information. For the avoidance of doubt, we do not sell or share (as defined by the CCPA) your personal information.

If you are a resident of Virginia, USA, as of January 1, 2023, you may exercise the following rights regarding your personal information:

• Confirm whether we are processing your personal information and access such personal information;
• Correct inaccuracies in your personal information;
• Delete your personal information;
• Obtain a copy of the personal information you provided to us; and
• Opt-out of the processing of your personal information for the purposes of: (i) targeted advertising, (ii) the sale of your personal information, or (iii) profiling that produces legal or similarly significant effects concerning you.

As provided by the VCDPA, you have the right to not be discriminated against for exercising the above rights.
You may exercise your Virginia privacy rights by sending a written request to privacy@netshorttv.com. If we deny your request due to insufficient information for an effective response, you may appeal by sending a written complaint to privacy@netshorttv.com. For the avoidance of doubt, we do not sell your personal information or use your personal information for targeted advertising or profiling.

If you are a resident of Colorado, USA, as of July 1, 2023, you may exercise the following rights regarding your personal information:
a. Access your personal information;
b. Correct inaccuracies in your personal information;
c. Delete your personal information;
d. Obtain a copy of the personal information you provided to us; and
e. Opt-out of the processing of your personal information for the purposes of: (i) targeted advertising, (ii) the sale of your personal information, or (iii) profiling that produces legal or similarly significant effects concerning you.
As provided by the CPA, you have the right to not be discriminated against for exercising the above rights.
You may exercise your Colorado privacy rights by sending a written request to privacy@netshorttv.com. If we deny your request due to insufficient information for an effective response, you may appeal by sending a written complaint to privacy@netshorttv.com.
For the avoidance of doubt, we do not sell your personal information or use your personal information for targeted advertising or profiling.

If you are a resident of Connecticut, USA, as of July 1, 2023, you may exercise the following rights regarding your personal information:

1. Confirm whether we are processing your personal information and access your personal information;
2. Correct inaccuracies in your personal information;
3. Delete your personal information;
4. Obtain a copy of the personal information you provided to us; and
5. Opt-out of the processing of your personal information for the purposes of: (i) targeted advertising, (ii) the sale of your personal information, or (iii) automated profiling that produces legal or similarly significant effects concerning you.

As provided by the CDPA, you have the right to not be discriminated against for exercising the above rights.
You may exercise your Connecticut privacy rights by sending a written request to privacy@netshorttv.com. If we deny your request due to insufficient information for an effective response, you may appeal by sending a written complaint to privacy@netshorttv.com. For the avoidance of doubt, we do not sell your personal information or use your personal information for targeted advertising or profiling.

If you are a resident of Utah, USA, as of December 31, 2023, you may exercise the following rights regarding your personal information:

1. Confirm whether we are processing your personal information and access your personal information;
2. Delete your personal information;
3. Obtain a copy of the personal information you provided to us; and
4. Opt-out of the processing of your personal information for the purposes of: (i) targeted advertising, or (ii) the sale of your personal information.

As provided by the UCPA, you have the right to not be discriminated against for exercising the above rights.
You may exercise your Utah privacy rights by sending a written request to privacy@netshorttv.com. If we deny your request due to insufficient information for an effective response, you may appeal by sending a written complaint to privacy@netshorttv.com.
For the avoidance of doubt, we do not sell your personal information or use your personal information for targeted advertising or profiling.

If you are a user in Mainland China, unless otherwise provided by law or administrative regulations, you have the following rights regarding your personal information:
a. The right to know, decide, and the right to restrict or refuse the processing of your personal information.
b. The right to access and copy your personal information, except in special circumstances prescribed by law.
c. The right to request the transfer of your personal information to a personal information processor designated by you.
d. If you find that the personal information we process about you is inaccurate or incomplete, you have the right to request correction or supplementation.
e. You have the right to request the deletion of your personal information in the following circumstances:
(Ⅰ) The purpose of processing has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose;
(Ⅱ) NT ceases to provide products or services, or the retention period has expired;
(Ⅲ) You withdraw your consent;
(Ⅳ) Other circumstances prescribed by law or administrative regulations.
(Ⅴ) If deleting your personal information is technically difficult to achieve, NT will cease processing except for storage and taking necessary security measures.
(Ⅵ) The purpose of processing has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose;
f. You have the right to ask us to explain this Privacy Policy.

If you have any questions or requests regarding your data rights, you may contact us by sending an email to privacy@netshorttv.com.
After you withdraw your consent, we will no longer process your personal information. However, your decision to withdraw consent will not affect the personal information processing that was previously carried out based on your authorization.

9. Security of User Personal Information

Protecting the security of your personal information is our top priority. To prevent unauthorized access, use, disclosure, or destruction of your personal information, we will take strict security measures. We will adopt physical, technical, and administrative measures that comply with relevant laws and industry standards. For example, we use firewalls, encryption technologies, and other automated software designed to prevent fraud and identity theft; we only store information on devices and in locations that provide a high degree of protection. We also strictly monitor data access around the perimeter and at building entrances through video and other electronic surveillance.
We will minimize the storage of sensitive information on our servers to protect your privacy. We will also contractually require our partners to protect user data.
Typically, NT will retain information for one (1) year unless otherwise required by applicable law. The criteria for determining the retention period include: (i) the length of time personal information needs to be retained to provide services and operate the business; (ii) the type of personal information collected; and (iii) whether we are subject to legal, contractual, or other similar obligations to retain data (e.g., mandatory data retention laws, government requests to retain data relevant to an investigation, or data that must be retained for litigation or disputes).

10. Children

We guarantee compliance with the Children's Online Privacy Protection Act (COPPA) and any applicable laws related to children. Furthermore, we do not knowingly collect any personal information from children we know to be under a certain age (as defined by applicable laws related to children).
If a parent or guardian discovers that their child has provided us with their personal information without their consent, the parent or guardian should contact us promptly. We will take reasonable measures to ensure that such information is deleted from our records.

11. Promotional Marketing

We may periodically send you information about our products, services, and content that may be of interest to you via email. If relevant laws require us to obtain your consent before sending you marketing messages, we will only send you such marketing messages after obtaining your consent.
If you do not wish to receive such marketing messages, you may unsubscribe at any time by following the instructions provided in the marketing message or by sending an email to privacy@netshorttv.com to request not to receive such messages.

NT Website Privacy Policy

1. Introduction

This NT Website Privacy Policy applies to the collection and use of information on the website, including information collected and used by NT when you browse and use the NT Website. Under the GDPR, NT is the data controller of your personal information.

2. Information We Collect

When you visit the NT Website, personal information that you voluntarily provide (e.g., name, date of birth, personal identification number, address, phone number, email address, occupation, educational background, work experience, and other relevant information) will be collected. Some information that you do not actively provide, such as browser type, domain name, IP address, pages viewed, and the duration of your visit using different technologies and methods, including the collection of IP addresses, Cookies, internet tags, and navigation data, may also be collected. To improve the quality of our services, we need your personal information to meet your individual needs and provide better service. NT has the right to take measures to verify the accuracy of the information you provide. If the information you provide is the personal information of others, you agree and warrant that you have obtained their permission.

3. How We Use Your Personal Information

The legal basis for processing your personal information is your consent. The personal information you provide to us may be used for the following purposes: (i) to provide you with NT's products, services, or related information; (ii) to register you for relevant events or training; (iii) to send you marketing information from us or our affiliated companies; (iv) to contact and respond to your requests and inquiries; (v) for business management, including data analysis; (vi) to provide you with personalized access and assistance when using the website; or (vii) to help us understand our users and improve our website.
We will periodically send you information about our products, services, and content that may be of interest to you via email. If relevant laws require us to obtain your consent before sending you marketing messages, we will only send you such marketing messages after obtaining your consent.
If you do not wish to receive such marketing communications, you may unsubscribe at any time by following the instructions provided in the marketing message or by sending an email to privacy@netshorttv.com to request not to receive such communications.

4. Disclosure of Your Personal Information

We employ third parties to provide services for us and to assist in the development and operation of the NT Website, including our cloud server providers, website analytics service providers (see our Cookie Policy for details), and email service providers. These third parties may access your personal information. We may also share your personal information with our affiliated companies for the purposes set out in this Privacy Policy.
If we believe that you have attempted to or have already abused or harmed the website, we will investigate and cooperate with relevant law enforcement agencies to protect our legal rights.
At the same time, we will provide your personal information as required or permitted by law to cooperate with court subpoenas, other similar legal proceedings, or government requests; or if we believe that such disclosure is necessary in accordance with the law, or to protect our legal rights and safety and/or those of other third parties (including advisors, law enforcement agencies, and judicial supervision departments). We may also transfer your personal information to a third party that acquires part or all of our assets, shares, or succeeds to part or all of our business through a merger, acquisition, restructuring, or other means.

5. International Transfer

If you are located in the European Economic Area (EEA), the personal information collected from you, including from the NT Website, will be transferred to countries outside the EEA (including Singapore, where the NT Website servers are located). You hereby explicitly consent to the transfer of your personal information to recipients located outside the EEA as described in this Privacy Policy, including to NT, NT's affiliated companies, and other recipients specified in this Privacy Policy.
To transfer personal information to NT's affiliated companies, NT has entered into the EU Standard Contractual Clauses ("SCCs"). You may request a copy of the SCCs by sending an email to privacy@netshorttv.com. To transfer personal information to AroundDeal, NT has entered into the EU Standard Contractual Clauses with AroundDeal ("AroundDeal SCCs"). You may request a copy of the AroundDeal SCCs by sending an email to privacy@netshorttv.com.
If you are located in Mainland China, the personal information we collect about you under this Policy will be stored within the territory of the People's Republic of China. We will not transfer your personal information outside of the country.

6. Your Data Rights

You have the right to access, modify, amend, or delete the personal information we may have collected about you. To exercise these rights, please contact privacy@netshorttv.com.
If you are located in the European Economic Area, you have the following rights (subject to limited exceptions): (i) to request access to, modification of, or deletion of your personal information; (ii) to restrict or object to the processing of your personal information; and (iii) to request an electronic copy of your personal information for transmission to another party or third party. You also have the right to lodge a complaint with your local data protection authority in the EEA regarding the processing of your personal information.

If you are a resident of California, USA, you may inquire about our collection and use of your personal information over the past 12 months, including:

• The categories of personal information we have collected.()
• The categories of sources from which we collect personal information.()
• The business or commercial purpose for collecting, selling, and/()or sharing personal information.
• The categories of third parties with whom we disclose personal information.
• The categories of personal information we sold, shared, or disclosed for a business purpose.
• The third parties to whom we sold, shared, or disclosed personal information for a business purpose.
• Your Rights. You may request a copy of the personal information we have collected about you in the past 12 months.
• You may request that we delete the personal information we have collected from you.
• You may request that we correct your personal information.

As provided by the CCPA, you have the right to not be discriminated against for exercising the above rights.
You may exercise your California privacy rights by (i) sending a written request to privacy@netshorttv.com or by mail to:Legal Department, Room 3-2-25, Building 3, Science and Technology Park, No. 37 Daoyi South Street, Shenbei New District, Shenyang, Liaoning, China; or (ii) sending a written request to privacy@netshorttv.com to limit the use of your sensitive personal information.
For the avoidance of doubt, we do not sell or share (as defined by the CCPA) your personal information.

If you are a resident of Virginia, USA, as of January 1, 2023, you may exercise the following rights regarding your personal information:

• Confirm whether we are processing your personal information and access such personal information;
• Correct inaccuracies in your personal information;
• Delete your personal information;
• Obtain a copy of the personal information you provided to us; and
• Opt-out of the processing of your personal information for the purposes of: (i) targeted advertising, (ii) the sale of your personal information, or (iii) profiling that produces legal or similarly significant effects concerning you.

As provided by the VCDPA, you have the right to not be discriminated against for exercising the above rights.
You may exercise your Virginia privacy rights by sending a written request to privacy@netshorttv.com. If we deny your request due to insufficient information for an effective response, you may appeal by sending a written complaint to privacy@netshorttv.com.
For the avoidance of doubt, we do not sell your personal information or use your personal information for targeted advertising or profiling.

If you are a citizen of the People's Republic of China (Mainland), unless otherwise provided by law or administrative regulations, you have the following rights regarding the processing of your personal information:
(1) The right to know, decide, and the right to restrict or refuse the processing of your personal information. (2) The right to access and copy your personal information, except in special circumstances prescribed by law.
(3) The right to request the transfer of your personal information to a personal information processor designated by you.
(4) If you find that the personal information we process about you is inaccurate or incomplete, you have the right to request correction or supplementation.
(5) You have the right to request the deletion of your personal information in the following circumstances:
- The purpose of processing has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose;
- NT ceases to provide products or services, or the retention period has expired;
- You withdraw your consent;
- NT processes personal information in violation of laws, administrative regulations, or agreements;
- Other circumstances prescribed by laws and administrative regulations.
If deleting your personal information is technically difficult to achieve, we will cease processing other than storage and taking necessary security measures.

7. Security of Your Personal Information

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. We will only retain your personal information when necessary. For any personal information collected on the website in any manner, we will only retain it for one year.

8. Protection of Minors

This website does not intentionally collect the personal information of minors. Any personal information of a minor that you provide must be with the prior consent of the minor's parent or guardian. The definition of a minor is determined by the laws applicable to this Privacy Policy.

9. Use of Cookies and Other Tracking Technologies

When you visit the NT Website, NT may use cookies or other technologies (collectively, "Cookies") to collect your personal information. For more information, please read our Cookie Policy.

10. External Websites and Links

This website may contain links and references to websites owned or operated by third-party vendors and other third parties ("External Websites"). NT is not responsible for the availability of, or the content located on or through, any External Website, including any webcasting or other form of transmission received from any External Website. If you have any concerns regarding such links or the content on such External Websites, you should contact the administrator for those External Websites. NT permits third parties to link to NT's homepage, provided that NT is notified of such links and does not object to them. NT reserves the right to unilaterally revoke any consent it may at any time give to any link, including links to its homepage. Any External Websites provided are only for your convenience. The inclusion of any link or reference on this website does not imply endorsement of the External Website.

11. Copyright

All website content, design, text, graphics, images, logos, buttons, icons, interfaces, audio and video clips, and all combinations thereof are the exclusive property of NT or its respective content providers and are protected by the laws of the Hong Kong Special Administrative Region and international copyright laws. All software used on the site is the property of NT or its respective software suppliers and is protected by the laws of the Hong Kong Special Administrative Region and international copyright laws and other applicable laws and treaties. Users of the site shall not send/upload any content to this site that infringes on the copyrights or other intellectual property rights of others.

12. Trademarks

All trademarks, service marks, and trade names (collectively, the "Marks") used on the site are proprietary to NT. The Marks may not be used in connection with any product or service that is not NT's, in any manner that is likely to cause confusion among consumers, or in any manner that disparages or discredits NT.

13. Online Conduct

NT has the right to prohibit any conduct that it, in its sole discretion, believes restricts or inhibits any other person from using this website. You agree to use this website only for lawful purposes and agree not to engage in the prohibited conduct described above. You agree not to upload or transmit to this website any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, sexually explicit, profane, hateful, racially, ethnically, or otherwise objectionable material of any kind, including but not limited to any material that encourages conduct that would constitute a criminal offense, give rise to civil liability, or otherwise violate any applicable local, state, national, or international law.

14. Termination of Use

NT may, in its sole discretion, terminate or suspend your access to all or part of the website without notice or liability for any reason, including any violation of applicable law, this Privacy Policy, or conduct that is harmful to the interests of other users, third parties, retailers, sponsors, licensors, service providers, or the website. Given the rapid development of internet technology, we will update this Privacy Policy from time to time. All revisions will be announced on the website.

NT Cookie Policy

What are Cookies?
Cookies are small text files that websites save on the device you are using to browse. They are saved and processed by your web browser and are read on your next visit to the site.
Generally, cookies are classified into the following four categories based on their purpose:
Strictly Necessary Cookies. These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site.
Preference Cookies, also known as "Functionality Cookies." These cookies allow a website to remember choices you have made in the past, like what language you prefer, what region you would like weather reports for, or what your username and password are so you can automatically log in.
Statistics Cookies, also known as "Performance Cookies." These cookies collect information about how you use a website, like which pages you visited and which links you clicked on. Their sole purpose is to improve website functionality. They may include analytics services provided by third parties, as long as the cookies are for the exclusive use of the owner of the website visited.
Marketing Cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad.

What types of cookies does NT use?
NT uses only the following two types of cookies for the purposes below:
Preference Cookies. NT uses preference cookies solely to remember your past settings (e.g., language) to optimize the information displayed to you.
Analytics Cookies. NT also uses third-party Google Analytics cookies to help us understand how our website is used. Google Analytics collects first-party cookies, data related to the device or browser, IP address, or on-site/app activities to measure and report statistics about user interactions on the website. Google provides NT with the statistical services of Google Analytics. For more information about Google Analytics cookies, please read here.

Contact Us

If you have any questions or suggestions about this Privacy Policy, please contact the NT Data Protection Officer at privacy@netshorttv.com. You can also contact us at: 190 WOODLANDS INDUSTRIAL PARK E5, #08-13 WOODLANDS BIZHUB, SINGAPORE (757516)
Please ensure you include your name (and the full name of your company if you are inquiring on behalf of a company), address, email address, or other contact information so that we can respond to your message promptly.